CONSTITUTIONAL LAW (CASE DIGEST)

REAGAN VS CIR
30 SCRA 968
GR. NO. L-26379
December 27, 1969

PONENTE: FERNANDO.,J

FACTS:

Petitioner herein is a civilian employee on corporation providing technical support to the United States
Air Force in the Philippines. Petitioner sold a car to an American army. The Sale was made in their air-
based here in the philippines. The sale was subject to tax by the respondent, on which the petitioner
invoked that the sale was made in a "foreign territory " and therefore beyond our jurisdictional power to
tax. The petitioner is asking for refund in the amount of Php 2,979.00 on which later on denied by the
court of tax appeals. Hence this appeal to the Supreme Court.

ISSUE: WON, the respondent CIR can legally collect tax from the petitioner?

RULING:

YES. The military air-based on where the sale happened was not a foreign territory both in political and
geographical sense. The sale having taken place on what indisputably is Philippine territory, petitioner's
liability for the income tax due as a result thereof was unavoidable. The Court of Tax Appeals was affirmed.
Hence, the petitioner is liable for tax.

MACARIOLA VS ASUNCION
14 SCRA 77
AM NO. 133-J
MAY 31, 1982

Ponente: Makasiar.,J

FACTS:

One Bernardita Macariola was a petitioner to a partition of land against reyes's on which the said partition
was lodged to the sala of the respondent Judge Asuncion. Times passed by, the partition was approved
by Judge Asuncion. One the land was bought by one Dr. Galapon and later sold to Judge Asuncion and his
wife. Somewhat on August 31,1966 Judge Asuncion conveyed the land to one company on where he is
the President and his wife and Mr. Galapon are stockholders. Macariola charged Judge Asuncion with acts
of "unbecoming a judge" for violating the provisions of Art. 1941 par. 5 of the NCC, Art. 14 par. 1 and 5 of
Code of Commerce, Sec. 3 par H of RA 3019, Sec 12, Rule 17 of Civil Service Rules and Canon 25 of the
Cabins of Judicial Ethics.
ISSUE: WON, the respondent Judge violated the above-mentioned provisions?

RULING:

No. Respondent Judge did not violated the mentioned provisions constituting of "acts unbecoming a
Judge". Respondent Judge did not buy the land directly when that partition of a land was on his sala, but
to Mr. Galapon therefore the said land was no longer subject for litigation. Art. 14 of the Code of
Commerce has no legal and binding effect as it is abrogated because whenever a there is a change in
sovereignty, the political law of the former sovereign are automatically abrogated.

Hence, Judge Asuncion should not be held liable.

ICHONG VS HERNANDEZ
101 PHIL 115
GR. NO. L-7995
MAY 31, 1957

PONENTE: LABRADOR.,J

FACTS: The Congress pass and act which prohibit be engaged in business trade in the philippines.
Petitioner question the constitutionality of the Act, contending that: (1) it denies to alien residents the
equal protection of the laws and deprives of their liberty and property without due process of law; (2) the
subject of the Act is not expressed or comprehended in the title thereof; (3) the Act violates international
and treaty obligations of the Republic of the Philippines. Respondent on the other hand contends that the
Act was passed in the valid exercise of the police power of the State, which exercise is authorized in the
Constitution in the interest of national economic survival.

ISSUE: WON, The Act was unconstitutional ? WON it violates due process?

RULING: NO. The law does not violate the equal protection clause of the Constitution because sufficient
grounds exist for the distinction between alien and citizen in the exercise of the occupation regulated, nor
the due process of law clause, because the law is prospective in operation and recognizes the privilege of
aliens already engaged in the occupation and reasonably protects their privilege. The petition is hereby
denied, with costs against petitioner.

MAQUERA VS BORRA
GR. NO. L-24761
SEPTEMBER 7, 1965

PONENTE: PER CURIAM

FACTS: Petitioner question the constitutionality of RA 4422 which adds some qualification of persons in
running into public office. He contends that it is against the Constitution.

ISSUE: WON or not RA 4421 is unconstitutional?

RULING: The Constitution, in providing for the qualification of Congressmen, sets forth only age,
citizenship, voting and residence qualifications. No property qualification of any kind is thereunder
required. Since the effect of Republic Act 4421 is to require of candidates for Congress a substantial
property qualification, and to disqualify those who do not meet the same, it goes against the provision of
the Constitution which, in line with its democratic character, requires no property qualification for the
right to hold said public office. Hence the law was declared UNCONSTITUTIONAL.

CAMACHO VS CORESIS
GR NO. 134372
AUGUST 22, 2002

PONENTE: QUISIMBING.,J

FACTS: Petitioner invoked that Dr. Daleon (respondent) was violating the university code, and the law by
giving his students of passing grade even if they don't come into class. The respondent here contends that
those students was in a special session on which afterward affirmed by the School Board of Regents.
Petition appeal to the ombudsman stating the alleged wrong practices of Dr. Daleon, ombudsman
dismissed the appeal in favor of the respondent. Hence this appeal for certiorari.

ISSUE: WON, petitioners contention is correct?

RULING NO. We agree with respondents position on the primacy of academic freedom in regard to higher
institutions of learning. Dr. Daleon's teaching style, validated by the action of the USP Board of Regents,
is bolstered by the constitutional guarantee on academic freedom. Academic freedom is two-tiered that
of the academic institution and the teachers. Institutional academic freedom includes the right of the
school or college to decide for itself, its aims and objectives and the methods on how best to attain them,
free from outside coercion or interference save possibly when the overriding public welfare calls for some
restraint. Academic freedom also accords a faculty member the right to pursue his studies in his particular
specialty. Petition is dismissed for lack of merit.

DEMETRIA VS ALDABA
GR NO. 71977
FEBRUARY 27, 1987

PONENTE: FERNA.,J

FACTS: Petitioner herein is questioning the constitutionality of PD NO. 1177 on the ground that: 1.) section
44 of presidential decree no. 1177 is repugnant to the constitution as it fails to specify the objectives and
purposes for which the proposed transfer of funds are to be made. 2.) section 44 of presidential decree
no. 1177 allows the president to override the safeguards, form and procedure prescribed by the
constitution in approving appropriations. According to the petitioner this Decree was a violation of the
Doctrine of Separation of Powers.

ISSUE: WON, PD NO. 1177 is unconstitutional?

RULING: Paragraph 1 of Section 44 of P.D. No. 1177 unduly over extends the privilege granted under said
Section 16[5]. It empowers the President to indiscriminately transfer funds from one department, bureau,
office or agency of the Executive Department to any program, project or activity of any department,
bureau or office included in the General Appropriations Act or approved after its enactment, without
regard as to whether or not the funds to be transferred are actually savings in the item from which the
same are to be taken, or whether or not the transfer is for the purpose of augmenting the item to which
said transfer is to be made. It does not only completely disregard the standards set in the fundamental
law, thereby amounting to an undue delegation of legislative powers, but likewise goes beyond the tenor
thereof. Indeed, such constitutional infirmities render the provision in question null and void.

MARIANO VS. COMELEC

GR NO. 118577
MARCH 7, 1995

PONENTE: PUNO.,J

FACTS:

This is a petition assailing certain provisions of Republic Act No. 7854 as unconstitutional. R.A. No. 7854 is
entitled, "An Act Converting the Municipality of Makati Into a Highly Urbanized City to be known as the
City of Makati." They argue that by providing that the new city shall acquire a new corporate existence,
section 51 of R.A. No. 7854 restarts the term of the present municipal elective officials of Makati and
disregards the terms previously served by them. In particular, petitioners point that section 51 favors the
incumbent Makati Mayor, respondent Jejomar Binay, who has already served for two (2) consecutive
terms.

ISSUE: WON, the above-mentioned act is unconstitutional?

RULING: We cannot entertain this challenge to the constitutionality of section 51. The requirements
before a litigant can challenge the constitutionality of a law are well delineated. They are: 1) there must
be an actual case or controversy; (2) the question of constitutionality must be raised by the proper party;
(3) the constitutional question must be raised at the earliest possible opportunity; and (4) the decision on
the constitutional question must be necessary to the determination of the case itself.5 Petitioners have
far from complied with these requirements. The petition is premised on the occurrence of many
contingent events, i.e., that Mayor Binay will run again in this coming mayoralty elections; that he would
be re-elected in said elections; and that he would seek re-election for the same position in the 1998
elections. Considering that these contingencies may or may not happen, petitioners merely pose a
hypothetical issue which has yet to ripen to an actual case or controversy.

Hence, the above-mentioned act is constitutional.

JOYA VS PCGG
 GR NO. 96541
AUGUST 24, 1993

PONENTE: BELLOSILLO.,J

FACTS:

Petitioners claim that as Filipino citizens, taxpayers and artists deeply concerned with the preservation
and protection of the country's artistic wealth, they have the legal personality to restrain respondents
Executive Secretary and PCGG from acting contrary to their public duty to conserve the artistic creations
as mandated by the 1987 Constitution, particularly Art. XIV, Secs. 14 to 18, on Arts and Culture, and R.A.
4846 known as "The Cultural Properties Preservation and Protection Act," governing the preservation and
disposition of national and important cultural properties. Petitioners also anchor their case on the premise
that the paintings and silverware are public properties collectively owned by them and by the people in
general to view and enjoy as great works of art. They allege that with the unauthorized act of PCGG in
selling the art pieces, petitioners have been deprived of their right to public property without due process
of law in violation of the Constitution.

ISSUE: WON PCGG act with grave abuse of discretion?

RULING:

Petitioners have failed to show that respondents Executive Secretary and PCGG exercised their functions
with grave abuse of discretion or in excess of their jurisdiction. The rule is settled that no question
involving the constitutionality or validity of a law or governmental act may be heard and decided by the
court unless there is compliance with the legal requisites for judicial inquiry, namely: that the question
must be raised by the proper party; that there must be an actual case or controversy; that the question
must be raised at the earliest possible opportunity; and, that the decision on the constitutional or legal
question must be necessary to the determination of the case itself. But the most important are the first
two (2) requisites.

WHEREFORE, for lack of merit, the petition for prohibition and mandamus is DISMISSED.

KMU LABOR CENTER VS GARCIA

GR NO. 115381
DECEMBER 23, 1994

PONENTE: KAPUNAN.,J

FACTS:

Sometime in March, 1994, private respondent PBOAP, availing itself of the deregulation policy of the
DOTC allowing provincial bus operators to collect plus 20% and minus 25% of the prescribed fare without
first having filed a petition for the purpose and without the benefit of a public hearing, announced a fare
increase of twenty (20%) percent of the existing fares. Petitioner KMU filed a petition before the LTFRB
opposing the upward adjustment of bus fares, which the LTFRB dismissed for lack of merit.

ISSUE: WON, the action of LTFRB is unconstitutional?

RULING:

YES. Under section 16(c) of the Public Service Act, the Legislature delegated to the defunct Public Service
Commission the power of fixing the rates of public services. Respondent LTFRB, the existing regulatory
body today, is likewise vested with the same under Executive Order No. 202 dated June 19, 1987.
However, nowhere under the aforesaid provisions of law are the regulatory bodies, the PSC and LTFRB
alike, authorized to delegate that power to a common carrier, a transport operator, or other public
service.

OPLE VS TORRES
293 SCRA 141
GR NO. 127685
JULY 23, 1998

PONENTE: PUNO.,J

FACTS:

This is a petition raised by Senator Blas Ople to invalidate the Administrative Order No. 308 or the
Adoption of a National Computerized Identification Reference System issued by President Fidel V. Ramos.
The petitioner contends that the said A.O. will violates the citizens right of privacy as guaranted by the
constitution.

ISSUE: Whether or not A.O. No. 308 violates the right of privacy.

RULING:

Yes. The right to privacy as such is accorded recognition independently of its identification with liberty; in
itself, it is fully deserving of constitutional protection. The right of privacy is guaranteed in several
provisions of the Constitution: "Sections 3 (1), 1, 2, 6, 8 and 17 of the Bill of Rights" The right to privacy is
a fundamental right guaranteed by the Constitution, hence, it is the burden of government to show that
A.O. No. 308 is justified by some compelling state interest. The petition is granted and declared the
Administrative Order No. 308 entitled "Adoption of a National Computerized Identification Reference
System" null and void for being unconstitutional.

PHILIPPINE AGILA SATELLITE VS. LICHAUCO

GR NO. 134887
MAY 3, 2006

PONENTE: TINGA.,J
FACTS:

Petitioners filed an action against the new DOTC Secretary Lichauco for allegedly having awarded the
orbital slot to an unknown awardee. The first cause of action, for injunction, sought to establish that the
award of orbital slot 153º East Longitude should be enjoined since the DOTC had previously assigned the
same orbital slot to PASI. The second cause of action, for declaration of nullity of award, averred that the
award to the unknown bidder is null and void, as it was rendered by Lichauco beyond her authority.

ISSUE: Would the doctrine of non-suability of the State find application in this case?

RULING:

NO. The Court rules that the defense of state immunity from suit do not apply since said causes of action
cannot be properly considered as suits against the State in constitutional contemplation. These causes of
action do not seek to impose a charge or financial liability against the State, but merely the nullification
of state action. The prayers attached to these two causes of action are for the revocation of the Notice of
Bid and the nullification of the purported award, nothing more. Had it been so that petitioner additionally
sought damages in relation to said causes of action, the suit would have been considered as one against
the State. Had the petitioner impleaded the DOTC itself, an unincorporated government agency, and not
Lichauco herself, the suit would have been considered as one against the State. But neither circumstance
obtains in this case.

FARULAN VS CTA
GR NO. 42204
JANUARY 23, 1993

PONENTE: ROMERO.,J

FACTS:

On August 20, 1976, private respondent filed a petition asking for the release of the questioned goods
which this Court denied. After several motions for the early resolution of this case and for the release of
goods and in view of the fact that the goods were being exposed to the natural elements, we ordered the
release of the goods on June 2, 1986. Consequently, on July 26, 1986, private respondent posted a cash
bond of P149,443.36 to secure the release of 64 bales out of the 80 bales originally delivered on January
30, 1972. Sixteen bales remain missing.

Private respondent alleges that of the 143,454 yards (64 bales) released to Bagong Buhay, only 116,950
yards were in good condition and the 26,504 yards were in bad condition. Consequently, private
respondent demands that the Bureau of Customs be ordered to pay for damages for the 43,050 yards it
actually lost.

ISSUE: WON, the Collector of Customs may be held liable for the 43,050 yards actually lost by private
respondent?

RULING:
In the case at bar, although it cannot be denied that private respondent caused to be prepared through
its customs broker a false import entry or declaration, it cannot be charged with the wrongful making
thereof because such entry or declaration merely restated faithfully the data found in the corresponding
certificate of origin, certificate of manager of the shipper, the packing lists and the bill of lading which
were all prepared by its suppliers abroad. If, at all, the wrongful making or falsity of the documents above-
mentioned can only be attributed to Bagong Buhay's foreign suppliers or shippers.

With regard to the second requirement on falsity, it bears mentioning that the evidence on record,
specifically, the decisions of the Collector of Customs and the Commissioner of Customs, do not reveal
that the importer or consignee, Bagong Buhay Trading had any knowledge of any falsity on the subject
importation.

WHEREFORE, the decision of the respondent Court of Tax Appeals is AFFIRMED.

TORIO VS FONTANILLA
85 SCRA 99
G.R. No. L-29993
OCTOBER 23, 1978

PONENTE:

FACTS:

On October 21, 1978, the Municipal Council of Malasiqui, Pangasinan passed Resolution No. 156 whereby
it resolved to manage the 1959 Malasiqui town fiesta celebration on January 21, 22, and 23, 1959.
Resolution No. 182 was also passed creating the town fiesta committee with Jose Macaraeg as Chairman.
The amount of P100.00 was also appropriated for the construction of two stages, one for the zarzuela and
the other for the cancionan. On January 22, while in the midst of the zarzuela, the stage collapsed, pinning
Vicente Fontanilla who died thereafter. The heirs of Fontanilla filed a petition for recovery of damages.
Defendant councilors contend that they are merely acting as agents of the municipality.

ISSUE:
1) Is the celebration of a town fiesta authorized by a municipal council a governmental or a corporate
function of the municipality?
2) Are the councilors liable for the death of Fontanilla?

RULING:

The holding of the town fiesta in 1959 by the municipality was an exercise of a private or proprietary
function of the municipality. The provision on Section 2282 of the Revised Administrative Code simply
gives authority to the municipality to celebrate a yearly fiesta but it does not impose upon it a duty to
observe one. It follows that under the doctrine of respondent-superior, the municipality is held liable for
damages for the death of Fontanilla. Since it is established that the municipality was acting a proprietary
function, it follows that it stands on the same footing as an ordinary private corporation where officers
are not held liable for the negligence of the corporation merely because of their official relation to it. Thus,
the municipal councilors are absolved from any criminal liability for they did not directly participate in the
defective construction of the stage.

DFA VS NLRC
G.R. No. 113191
SEPTEMBER 18, 1996

PONENTE: VITUG.,J

FACTS:

Private respondent initiated NLRC-NCR Case for his alleged illegal dismissal by Asian Development Bank
and the latter's violation of the "labor-only" contracting law. Two summonses were served, one to the
ADB and the other through the DFA. Forthwith, the ADB and the DFA notified respondent Labor Arbiter
that the ADB, as well as its President and Office, were covered by an immunity from legal processes except
for borrowing, guaranties or the sale of securities pursuant to the Agreement Establishing the Asian
Development Bank (the "Charter") and the Agreement Between the Bank and the Government of the
Philippines regarding the Banker's Headquarters (the "Headquarters Agreement). The Labor Arbiter took
cognizance of the complaint on the impression that the ADB had waived its diplomatic immunity from
suit. The ADB did not appeal the decision. Instead, the DFA referred the matter to the NLRC; in its referral,
the DFA sought a "formal vacation of the void judgement".

ISSUE: WON, ADB is correct in invoking its immunity from suit?

RULING:

Yes. The stipulations of both the Charter and the Headquarters Agreement establish that, except in the
specified cases of borrowing and guarantee operations, as well as the purchase, sale and underwriting of
securities, the ADB enjoys immunity from legal process of every form. The Bank's officers, on their part,
enjoy immunity in respect of all acts performed by them in their official capacity. The granting of these
immunities and privileges are treaty covenants and commitments voluntarily assumed by the Philippine
Government. Being an international organization that has been extended diplomatic status, the ADB is
independent of the municipal law.